SEC v. Christopher M. Gibson (front running, 2016)

Dismissed

✓ Checked against the primary document on October 4, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In March 2016 the SEC instituted administrative proceedings against adviser Christopher Gibson over alleged front running. On June 2, 2023 the Commission dismissed the proceeding, with other pending proceedings, as a matter of discretion after a review of an internal control deficiency.

The record

What was ordered

Civil penalty

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Disgorgement

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Prejudgment interest

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Total relief

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Alleged gain

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A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Division of Enforcement alleges that Gibson, who advised a private fund that had put most of its assets into Tanzanian Royalty Exploration stock, sold all the shares in his personal and two controlled accounts at about $4.04 the day before he began selling the fund's 3.7 million shares, which the order calls front running. It also alleges that on October 18, 2011 he had the fund buy over 680,000 shares from its largest investor so that investor could exit at a favourable price, and that in late October and early November 2011 he bought put options for himself and his then-girlfriend, and advised his father to do likewise, before the fund's last sale.

For the regulator's own account of the facts, read the primary document linked above.

The SEC's administrative file for proceeding 3-17184 shows an order of June 2, 2023 dismissing the proceeding. The order lists Gibson among a group of pending administrative proceedings that the Commission chose to dismiss as a matter of discretion after reviewing a control deficiency in how enforcement and adjudication staff were separated, while saying the review found no evidence that it harmed any respondent. The order does not decide the allegations, so the dismissal is not a finding that Gibson did or did not engage in front running. Checked on 2026-10-04.

What technique is this, and how does it work?

This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.

• Front running — see how it works, what statute it engages, and every other action tagged the same way.

Timeline

1. 2016-03-29 Administrative proceeding instituted (cease-and-desist)
2. 2023-06-02 Commission dismisses proceeding 3-17184 as a matter of discretion

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

• SEC order
• SEC order dismissing proceedings (June 2, 2023)
• SEC administrative proceeding file 3-17184

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Related actions

Other actions in the library sharing at least one technique tag with this one.

Record added September 10, 2026. submit a correction.